Things are still moving fast and furious in the spinach/E. coli crisis, although there is now some light at the end of the tunnel. Here is the Pundit’s fourth 10-point analysis of the constantly changing situation. You can read the three previous 10-point reviews here, here and here.
- Change in FDA advisory means the industry can sell spinach again. Late in the evening on Thursday, September 20, 2006, the FDA quietly and subtly changed its advice to consumers. On Thursday during the day, the advice read as follows:
FDA advises consumers to not eat fresh spinach or products that contain fresh spinach until further notice. Fresh spinach includes bagged spinach, spinach in a clamshell, and loose spinach purchased from retail establishments such as supermarkets, restaurants and farmers’ markets.
At this time, FDA has no evidence that frozen spinach, canned spinach and spinach included in pre-made meals manufactured by food companies are affected. These products are safe to eat.
If individuals believe they may have experienced symptoms of illness after consuming fresh spinach or fresh spinach-containing products, FDA recommends that they seek medical advice.
But consumers who check the FDA web site awoke on Friday to find it reading as follows:
The FDA, in working closely with the CDC and the State of California, has determined that the spinach implicated in the outbreak was grown in the following California counties: Monterey, San Benito, and Santa Clara.
Other produce grown in these counties is not implicated in this outbreak. Processed spinach (e.g., frozen and canned spinach) is also not implicated in this outbreak.
Effectively this ended FDA’s recommendation to not consume spinach, though it wasn’t until a 6:30 PM press conference on Friday evening that the FDA verbalized the switch.
There is no specific mechanism to assure consumers that the spinach available is from non-implicated areas other than labeling signage and in-store efforts. Much will depend on retail efforts. If retailers do a good job with reassuring customers, the product will sell. In fact, though consumers will be cautious, supply will be severely decreased because the three counties implicated are big producers. At this time of year, California produces about 75% of the spinach sold in the US, and these counties account for the bulk of that production.
If we don’t get the other three counties back on line soon, even modest customer acceptance and retail promotion of spinach will lead to shortages and high prices.
- Kudos to the association community. On Friday, September 22, 2006, the Produce Marketing Association, United Fresh Produce Association, Western Growers Association and the Alliance for Food and Farm held a conference call for the industry, which followed an earlier one held the previous Friday.
It was good to see the association community working together to solve such a serious industry problem.
It is tempting in a situation such as this for one association to try to steal the limelight from the others so as to convince industry members of its importance. There was precious little of that this time around.
There were plenty of differences behind the scenes, but the industry presented a unified front and used all its resources to deal with the issue at hand. A very strong performance.
- PMA consumer research. Bryan Silbermann, president of the Produce Marketing Association, gave a sneak preview of some quick consumer research sponsored by the association. When asked where consumers got information from regarding food safety, the most frequent response was personal experience, the second-most-frequent response was the FDA and government agencies, and the third-most-frequent response was the media.
He also reported that almost 70% of consumers thought the produce industry was doing an excellent or good job in dealing with the current spinach/E. coli crisis.
These are preliminary findings and more research is being done. I find the 70% number highly encouraging as consumer sentiment that the produce industry was cooperative and looking to do the right thing will be crucial in rebuilding consumer confidence and getting sales moving again.
The notion that people get their information from the FDA and government is problematic. Obviously, only a tiny portion of the population calls up the FDA and talks to them or even reads the FDA and CDC web sites. So people rarely get unadulterated advice from the government. What they get is governmental advice as filtered through the news media. This means a two-prong industry outreach program is required, both to shape governmental recommendations and to shape the way consumer media present these recommendations.
- Organic vs. conventional and fresh-cut vs. bulk. Two arenas of industry competition, long festering, have risen anew with the spinach/E. coli situation. One is a competition between organic and conventionally grown product; the other is a battle between fresh-cut and bulk product. The Pundit has been actively involved with these debates addressing what the spinach/E. coli controversy implies for fresh-cuts here and how the issue impacts organics here.
Whenever one raises differences, it can be controversial. Association leaders, almost as an occupational requirement, prefer harmony among their members. And, presented unfairly, arguments such as these could reduce consumer confidence in all produce.
But safety in food, as in other products, is rarely an all-or-nothing thing, and many corporations have used safety as a point of differentiation without bringing ruin on their industry. Volvo has for decades promoted the safety of its vehicles and its emphasis on engineering safety into each car. When Pan Am flew, it did so under the slogan “The World’s Most Experienced Airline” — which is a subtle way of saying “we are the safer choice.”
The reason some find this type of promotion unacceptable is because it implies that some produce is less safe than others. One of the reasons the industry is in this fix is we have sometimes wanted to present all produce as “perfectly safe”. This is understandable, but problematic, because it isn’t true. Just as it isn’t true in airlines and isn’t true in cars.
- State government promotion of Salinas Valley. The body blow that has been dealt in this current crisis is really to the Salinas Valley. The spinach crisis, the constant reminders in the media of past problems with lettuce and the publicity over the FDA letter to lettuce farmers are a flame set in the kindling of a pre-existing environment in which large-scale agribusiness was already the subject of attack.
It is all very unfair. The truth is that the Salinas Valley feeds countless millions with fresh product every day. When they have a problem such as this, it is going to be big, really big, because they distribute to every corner of the country and around the globe.
So it is very good news that the government of California, recognizing the stake California has in burnishing the image of the “Salad Bowl of the World”, is looking at running some kind of promotional campaign to promote the valley, the farmers who work it and the high quality produce it produces. Of course, this won’t happen until everyone is shipping again.
There is no place quite like Salinas in the whole world. It is a resource California would be wise to invest in.
- Getting Salinas back in production. With the FDA’s decision to lift the blanket recommendation not to eat spinach, the market can start up again. But until product is flowing from the three counties still under investigation in this crisis, the crisis is not truly resolved.
Now the problem is that the FDA is in a difficult spot. Everyone knows the odds are that whatever caused this outbreak is long since gone. But the FDA has to somehow announce that it has “done something” to insure food safety. So working with the industry, the tentative plan is to announce some kind of “Fresh-Start” program on a short-term basis to get the industry going again.
The proposal, not yet approved, is for a five-part program:
- An “industry restart cleaning”, in which all facilities are sanitized.
- A pre-harvest audit to make sure good agricultural practices are being followed.
- Monitoring of irrigation facilities and procedures.
- A review of all soil amendments
- And, if all this can’t be done or done satisfactorily, pre-harvest spinach testing.
How all this can be verified is still an open question, but there is a possibility that the California Dept. of Food and Agriculture might be willing to take on the task.
How quickly such a system can be up and running is unclear, but it doesn’t seem easy to do. Several weeks seems pretty optimistic.
- Temporary or permanent? Just spinach, or lettuce too? Industry is pushing hard that these requirements be temporary as part of a “Fresh-Start” program. But rent control in New York City was a temporary measure imposed during World War II and is still going strong. When I look at that list, I don’t see a thing on it that those who are concerned about food safety won’t want to make permanent.
I also don’t see anything on the list they won’t want to apply to lettuce as well as spinach.
- FDA teams in Salinas. The FDA currently has 20 investigators in the field functioning in multidisciplinary teams of four. By the end of the day Friday, they visited six growers and 10 fields. The impression they give is that the FDA is throwing all it’s got at this problem, which means the FDA is woefully unprepared for a serious act of terrorism. What if this were a case where thousands of people were dying? The FDA needs the capability to field hundreds of teams on a few hours’ notice.
- Was the recommendation to stop eating spinach too broad? One of the most hotly contested issues that will be debated forever is whether the FDA recommendation to stop eating all spinach was too broad. Tom Stenzel, President/CEO of the United Fresh Produce Association, tried to explain the FDA’s thinking by comparing it to 9/11 when, uncertain of the source or extent of danger, the government grounded all airlines.
I think this has always been the FDA’s position, but in this case, the danger was always known much more exactly. In the first case, the majority of illnesses came from people who bought bagged spinach. Because this product is, well, in a bag, we have a brand so it is a relatively easy thing to suggest a voluntary recall on those brands. It might be one brand, it might be 100 brands — but never on bagged product would there be a need to withdraw brands that were never implicated in the illnesses.
There were some reports that people purchased bulk spinach and others that they fell sick as a result of eating something at a restaurant or at a salad bar.
Once again, the industry has trace-back mechanisms. If you go to a retailer, you should be able to find out who they bought loose spinach from or who they bought foodservice-sized bags from. Once again, recalls could be done with those specific brands and suppliers.
What is the point of these expensive trace-back systems if the FDA isn’t going to use them to limit the extent of these recalls?
- Message. The problem with releasing some spinach and not other spinach is that it gives a mixed message to consumers regarding the safety of spinach and adds to the complexity of developing a consumer-based spinach message.
What should the industry message be? The temptation is to try to reassure consumers that they can eat with confidence. But you can’t overdo this because we can’t guarantee that this will be the last food safety outbreak we will ever have.
You can show care and concern; you can emphasize that farmers eat this product as well; you can show lots of women and children on the farm. But it is a bad idea to guarantee what can’t be guaranteed.
